Anti-Money
LaunderingAML / CTF

Money laundering is the process of concealing or converting funds derived from criminal activities so that illegally obtained proceeds appear legitimate.

It generally occurs in three stages:

Terrorist Financing (TF) involves obtaining or moving funds to support terrorist activities. Unlike money laundering, the source of funds used for TF may be either legal or illegal. The Company implements strict controls to prevent ML and TF risks, with particular attention to customer behavior that may indicate suspicious activity.

The Company has appointed a dedicated Compliance Officer (CO) in accordance with applicable gaming regulations. The CO is responsible for overall regulatory compliance, AML process management, and the monitoring of fraudulent activities. Key responsibilities include:

Our AML policies are aligned with international and Union of the Comoros regulations, including but not limited to:

The Company applies a risk-based AML / CTF approach focused on:

We utilize a sophisticated data processing system to support our AML activities, including:

Before making any deposit or placing any wager, customers must complete the registration process. The Customer Acceptance & Registration Policy is designed to confirm the suitability of prospective customers while ensuring compliance with AML standards.

Customers must be over 18 years of age and may hold only one account per website. Validation checks, including email, telephone number, and device data verification, help prevent duplicate accounts.

The Company prohibits registration by the following categories of individuals:

During registration, customers provide:

All customers must accept the Company's General Terms & Conditions, Privacy Policy, and AML terms during the registration process.

Registration is strictly limited to customers over the age of 18.

Verification is completed through our KYC process, which includes validating the information provided against valid identification documents.

Registration approval is subject to the successful completion of Customer Due Diligence, ensuring that only properly verified customers are permitted to complete the registration process.

Following registration, each customer is assigned a risk profile based on factors associated with ML / TF.

This categorization determines the level of monitoring and due diligence applied to each customer.

Access to the Service is blocked for the following jurisdictions in accordance with our licensing requirements and international AML obligations:

The level of Customer Due Diligence applied is proportionate to the customer's risk classification and determines the depth of verification procedures. Higher-risk profiles are automatically escalated to Enhanced Due Diligence (EDD).

Conducted during registration, the CDD process includes:

Required documents:

Documents must be current, legible, and of sufficient quality for review. Mobile phone bills are not accepted. Photographs and scans must display the full page, be unaltered, and presented in color.

Ongoing monitoring applies to all customer relationships and includes:

EDD applies in high-risk situations, including complex or high-value transactions and untraceable sources of funds. When EDD is triggered, the Company will:

Our KYC tools perform PEP and sanctions screening for all new and existing customers every six months to identify status changes. A confirmed positive PEP match on an existing account will trigger an immediate review, escalation to senior management, and, in most cases, account closure.

Accounts may be closed when violations are identified, including suspected ML / TF, fraud, or regulatory non-compliance. The Compliance Officer reviews suspicious behavior and determines whether a Suspicious Activity Report (SAR) should be filed. Account closure is conducted carefully in accordance with tipping-off restrictions.

The Company supports transactions only through licensed and regulated financial institutions, payment service providers (PSPs), and digital asset service providers that meet our compliance requirements. For AML purposes, cash transactions are prohibited. All deposits and withdrawals must be traceable through digital records provided by authorized institutions or through verifiable on-chain records.

Each deposit request is processed through PCI DSS-compliant payment gateways (for fiat currencies) or monitored digital wallet infrastructure (for digital assets), without the Company storing sensitive cardholder data. Incoming digital asset deposits are screened in real time against known illicit addresses. Funds are credited only after confirmation by the provider or blockchain network. If a transaction fails, the player will be notified and no balance adjustment will occur.

Players initiate withdrawal requests through the cashier interface by specifying the withdrawal amount and desired payment method. The requested amount is temporarily reserved from the balance while the transaction is under review, preventing double-spending.

Whenever possible, the Company processes withdrawals back to the original payment source, supporting transaction traceability and legitimacy verification. Where the original payment method is unavailable, funds will be transferred in accordance with our AML guidelines following renewed identity verification and compliance checks.

Suspicious activity may include, but is not limited to:

When suspicious activity is identified, the case is referred to the Compliance Officer for detailed review. The investigation may include examination of documents, transaction history, login records, devices used, source of funds, and any other relevant information.

If the investigation determines that there are reasonable grounds to suspect money laundering, terrorist financing, fraud, or other criminal activity, a Suspicious Activity Report (SAR) will be prepared. The report may be submitted to the appropriate Financial Intelligence Unit (FIU) and other regulatory or law enforcement authorities as required by applicable law.

All records relating to suspicious activities, internal investigations, SARs, and supporting documentation will be retained in accordance with applicable regulatory requirements and our record retention policy.

The Company maintains internal controls to ensure ongoing compliance with AML / CTF requirements. These controls include documented procedures, segregation of duties, risk-based monitoring, and oversight by the Compliance Officer.

All records relating to customer identification, due diligence, transactions, internal reports, and regulatory communications will be retained for the period required by applicable laws and licensing requirements.

Records must remain accessible for audits, regulatory inspections, and investigations conducted by competent authorities.

The Company conducts appropriate screening before hiring employees involved in AML, payments, compliance, and other sensitive operational functions.

Such screening may include identity verification, employment history checks, and other assessments deemed appropriate for the position.

All relevant employees receive periodic training on AML / CTF, fraud prevention, and regulatory requirements.

Training programs are updated regularly to reflect regulatory changes, newly identified risks, and industry best practices.

This AML Policy will be reviewed periodically to ensure ongoing alignment with regulatory requirements, licensing conditions, international standards, and emerging risks.

Whenever relevant changes occur in laws, regulations, supervisory guidance, or licensing requirements, the Company may update this policy without prior notice to reflect the new applicable obligations.

The Compliance Officer is responsible for overseeing the implementation of this policy, recommending updates when necessary, and ensuring its consistent application throughout the organization.